People of the Philippines vs. Jabinal

FACTS

Jose Jabinal, the accused, kept in his possession, custody and direct control a revolver with ammunition without first securing the necessary permit or license to possess the same. The accused admitted that he was in possession of such weapon however, he claimed to be entitled to exoneration because he had an appointment as Secret Agent from the Provincial Governor of Batangas and an appointment as Confidential Agent from the PC Provincial Commander. The said appointments expressly carried with them to be authority to possess and carry the firearm in question.

ISSUE

Whether the Macarandang and Lucero doctrines are applicable in the present case.

HELD

Yes, the Macarandang and Lucero doctrines are applicable in the present case. The interpretation upon a law by this Court constitutes a part of the law as of the date that law originally passed, since the Court’s construction merely establishes the contemporaneous legislative intent thus construed intends to effectuate. At the time appellant was found in possession of the firearm in question and when he arraigned by the trial court., the doctrine enunciated in Macarandang and Lucero, under which no criminal liability is attached to the accused, prevailed.